Tata Consultancy Services Ltd v Sengar

Tata Consultancy Services Ltd v Sengar

The court held that Tata was entitled to interim injunctive relief because the information obtained by Mr Sengar was confidential, he knew or ought to have known it was confidential, and there was a real risk of misuse or disclosure. The balance of convenience and adequacy of damages favoured Tata. The public interest and protected disclosure defences were not made out on the evidence. Delivery up and prohibitory orders were appropriate, but the defendant was not required at this stage to reveal his source.

Parties
Claimant: Tata Consultancy Services Limited; Defendant: Prashant Ashok Singh Sengar
Jurisdiction
England and Wales
Judgment Date
11 July 2014
Procedural Posture
Civil (interim Application) / Interlocutory (application for Interim Injunctive Relief)
Outcome
Interim injunctive relief granted (with modifications) in favour of the claimant.
Legal Topics
Interim Injunctions, Breach of Confidence, Confidential Information, Employment Discrimination, Protected Disclosure, Public Interest Disclosure, Torts (interference With Goods)
Civil Procedure Employment Law Equity and Trusts Interim Injunctions Breach of Confidence Confidential Information Employment Discrimination Protected Disclosure +2 more

Case Brief

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Parties

Tata Consultancy Services Limited

Claimant

Prashant Ashok Singh Sengar

Defendant

Procedural Posture

Civil (interim Application) / Interlocutory (application for Interim Injunctive Relief)

Legal Issues

  1. 1 Whether the claimant is entitled to interim injunctive relief requiring delivery up and deletion of confidential information obtained by the defendant
  2. 2 Whether the defendant is under an equitable duty of confidence regarding information obtained from the claimant's systems
  3. 3 Whether the public interest or protected disclosure defence applies to the defendant's possession and threatened use of the information

Ratio Decidendi

The court held that Tata was entitled to interim injunctive relief because the information obtained by Mr Sengar was confidential, he knew or ought to have known it was confidential, and there was a real risk of misuse or disclosure. The balance of convenience and adequacy of damages favoured Tata. The public interest and protected disclosure defences were not made out on the evidence. Delivery up and prohibitory orders were appropriate, but the defendant was not required at this stage to reveal his source.

Court Disposition

Interim injunctive relief granted (with modifications) in favour of the claimant.

Orders

  • Defendant to deliver up all hard and soft copies of confidential information obtained from Tata's 'Ultimatix' system to claimant's solicitors, Mishcon de Reya, to be held pending trial or further order.
  • Defendant prohibited from communicating or disclosing Tata's proprietary and confidential information or inducing others to provide such information.